Helpful answers on ADA barrier removal:

Where Can I find “Barrier Removal” requirements in the 2010 ADA Standards for Accessible Design?

There is a single reference to “Barrier Removal” in Section 101.2 Entitled “Effect on Removal of Barriers in Existing Facilities”.

Section 101.2 mentions the Department of Justice having sole discretion in enforcement, but where did the requirements go?

The companion document known as the “Americans with Disabilities Act Title III Regulations” covers “Barrier Removal”.

How can I get a copy of these regulations?

They are available for download on the ada.gov website.

Where do I find the specific requirements?

Sub-part C, Section 36.304 describes “Barrier Removal” requirements.

As I decide on which upgrades to make, what standard should I use?

The “2010 ADA Standards for Accessible design” contain the specific guidelines for making alterations to existing elements.

After calculating the 20% limit this money must be earmarked for various accessibility elements serving the Primary Function of the building.

Question: Can the 20% money be spent on the Primary Function area also, since some of the Primary Area needs new accessible features?

Answer: The 20% funds are intended for areas that are not within the Primary Function. Accessible routes from parking lots to the building entrance; accessible route from the entrance to the Primary Function Area; and the toilet rooms serving this Primary Function Area are all typical areas where the 20% funds must be spent.

 

NOTE: The answers provided are the opinion of the author, and should not be relied upon as ADA interpretations may vary.

The alteration requirements contain a limit on how much money is required to be spent on accessible elements serving the Primary Area remodel.

Question: What limits are placed on alteration costs within the Primary Function Area?

Answer: Altered Elements are to be upgraded to accessible standards to the maximum extent feasible.

Question: What is the 20% limit on accessible alteration costs for areas that serve the Primary Function Area.

Answer: Once the costs of alterations to a facility are known, there are costs that should be deducted. ADA 2010 Standards Section 36.403(b) notes that areas such as employee lounges and toilet rooms are not Primary Function areas and the cost of their remodel should be deducted. An example calculation follows:

 

NOTE: The answers provided are the opinion of the author, and should not be relied upon as ADA interpretations may vary.

Section 202.3 of the 2010 ADA Standards requires business occupancies that alter buildings, to do so in a manner which makes their facility readily accessible.

Question: What is the primary function rule for alterations?

Answer: Section 202.4 says, when primary or core areas of a building are remodeled, those areas or elements that are remodeled are required to be made accessible. This means that whatever elements you choose to alter, the construction is to be done by following new construction accessibility requirements.

Question: Are there exceptions to the new construction standards for alterations?

Answer: Many of the scoping requirements in Chapter 2 of the standards contain exceptions for altered facilities. The index in the back of the ADA Standards is useful for finding these; see “Alteration(s)”.

 

NOTE: The answers provided are the opinion of the author, and should not be relied upon as ADA interpretations may vary.

Field Tolerances are permitted during construction, but not allowed for design. It is important that designs do not include ± on dimensions, as this would provide a moving target rather than complying dimensions. The field “tolerance” or adjustment” is allowed in construction due to minor differences in finish materials and their installation.

An exception to the allowance for field tolerances is when the ADA specifies a range. (see ADA Standards Figure 604.2) Water Closets (toilets) are shown in the figure as having a minimum and maximum dimension. The tolerance is “built-in” to this range so that no field condition would warrant acceptable deviations. The designer may wish to show the range with a note to the installer that no field tolerance outside this range is allowed. Another common use of ranges is in ADA 2010 Standards Figure 505.4 Handrail Height. The dimensions are now expressed as 34”-38” to top of the handrail. Many designers are still using the old “center of handrail” dimension, which could lead to unacceptable field compliance.

Whenever the ADA indicates both endpoints of a range with a number, then designers and installers should be aware that the field tolerance is already a part of the dimension and lies between the two points.

 

NOTE: The answers provided are the opinion of the author, and should not be relied upon as ADA interpretations may vary.

The 2010 ADA Standards require permanent rooms to be identified with signs containing raised characters and Braille. If pictograms are included to designate a toilet room, then the raised characters and Braille are to be installed directly below the pictogram. If the establishment has both complying and non-complying toilet rooms, then signage designating the complying toilet room will also include the international symbol of accessibility.

The toilet room sign may then look like the following:

Sign installation height is primarily regulated by two dimensions:
a) Height to the lowest portion of Braille
b) Height to the lowest portion of the highest row of text

 

NOTE: The answers provided are the opinion of the author, and should not be relied upon as ADA interpretations may vary.

 ADA Accessibility Training News & Updates

Approximately 40 designers, code officials and consultants attended the two days of accessibility training during the week long 21st Annual AZBO Spring Education Seminar in Tucson this April. The highlights for each day serve as a reminder that a civil rights law can be enforced as a code or standard within the built environment. If you missed out on this opportunity, don’t worry. Stay tuned for updates on the upcoming ADA training classes this Fall in Prescott.

Highlights/Topics Discussed

Day 1 (April 17, 2014): The 2010 Standards for Accessible Design

• Arizona adoption requirements
• History and changes in the ADAAG since 1991
• Differences between enforcing a building code and the department of Justice Enforcing a Civil Rights Law
• How the ADA Standards differ from the IBC/ANSI
• What it means to be “Accessible”
• How to read, interpret, design, build to and enforce the ADA Standards
• Accessible routes and exceptions
• Working with defined terms
• Critique of ramps, curb ramps, door approaches, and other elements of accessible design

Day 2 (April 18, 2014): ADA for Existing Buildings and Alterations

• How the ICC existing building code has been coordinated with the ADA
• Landlord and tenant responsibilities
• Removal of barriers and how this requirement effects building design and permits
• Simplifying safe harbors
• Alterations and identifying primary use areas of a building
• The good and not-so-good truncated domes
• What a complete set of building plans should include
• Better understanding the mixed uses of buildings on a site and how to apply the ADA